Putting the Puzzle Together: P&P Manuals and ComplianceMelissa HabermanAssociate Dean, Student Financial Support ServicesMadison College

MASFAA 2015 Conference#myMASFAA

The P&P Puzzle

•Know the Goal•Review the Regulations•Ask Questions• Involve the Right People•Quality Assurance•Annual Review

Template• NASFAA Policy and Procedure Template• FSA Assessments• Colleagues!

Policy and Procedure Resources• NASFAA Student Aid Index• Information for Financial Aid Professionals (IFAP)

Publications• Federal Student Aid (FSA) Handbook• Electronic Code of Federal Regulations (E-CFR)

http://www.ecfr.gov/

Student Aid Index

Student Aid Index

Why Document?

• Attended a Conference• New Staff Member • Law and Regulation Changes• Audit or Program Review• Annual Review Process

CFR 668.16(b)(4) – Administrative CapabilityHas written procedures for or written information indicating the responsibilities of the various offices with respect to the approval, disbursement, and delivery of Title IV, HEA program assistance and the preparation and submission of reports to the Secretary.

Goal of the Documents

Who is the audience?

•Auditors• Internal documentation•Quick reference•Staff training

Ask Questions

• Who completes this process?• Institutional interaction? • Technology involved?• Frequency of process?• Meeting expectations?• Changes needed?

Involve the Right People

•Who does the work?•Who does it impact?•What type of policy is it?

Who is Involved – Two Examples

Exit Counseling• Loan Manager & Loan Processing Staff• Information Technology Staff

Death of a Student• Dean of Students• Registrar• Bursar• Financial Aid• Housing

Discussion Point: Death of a Student

• Does your office have a written policy?

• Do you include just the FA office obligations in the document or the whole process?

•Why might we want to include an overview of the whole campus process?

Quality Assurance

Is the process meeting expectations?• Who, what, when, how?• Internal audit, random sample• How frequently do you monitor?

Direct Loan Quality Assurance Requirement ReminderSee the November 13, 2013 Electronic Announcement

Discussion Point: Exit Counseling• Does your office have an exit counseling quality

assurance process?

• How do you confirm those that require exit counseling are identified?

• How do you confirm exit counseling was sent?

• Do you account for undeliverable email addresses?

Annual Policy Review• Schedule

All documents at once or each on an individual schedule?

• Is policy current?How many documents are written and

forgotten?

• Audit ReadyDoes what you say you do match actual

practice?

Where to Start? - Frequent Audit Issues

• Verification• Student Credit Balance• Entrance/Exit Counseling• R2T4 Calculations• Crime Awareness• Satisfactory Academic

Progress• Inaccurate Record

Keeping

Where to Start? - Frequent Audit Issues

• R2T4 Made Late• Consumer Information

Requirements• Pell

Over/Underpayments• Student Status

Inaccurate/Untimely Reporting• Lack of Administrative

Capability

Building R2T4 Policy

NASFAA PolicyAnd Procedure Tool

Building R2T4 PolicyHow many people are involved in R2T4 processing?

• Calculate Amount Owed• Adjust Award• Notify Student• Update Student Financial Account• Send Invoice to Student• Answer student Phone, Email, Walk-In

questions

Could involve 2-6 people and at least 2 offices.

Building R2T4 Policy

Who should write the policy?• Each person write their section?• One person write the entire thing?• One editor to put it all together?

Discussion Question:Who writes the R2T4 Policy at your institution?

Discussion: Verification Author(s)

Who writes the verification policy at your institution?

Do you have one author, a committee, different authors for different parts?

The P&P Puzzle

•Know the Goal•Review the Regulations•Ask Questions• Involve the Right People•Quality Assurance•Annual Review

Melissa HabermanAssociate DeanStudent Financial Support ServicesMadison Collegemahaberman@madisoncollege.edu

@ MelissaHaberman